Unreported / Non-Citable
Background
Jasman Dawone Holman was convicted of multiple sexual assault offenses against three women: Mariah L., Dolores E., and Maranda A. The incidents occurred between September 2021 and March 2022 at Holman's apartment in the Alexandria Hotel in Los Angeles. An information charged Holman with ten counts including forcible rape, sexual penetration by force, forcible oral copulation, sodomy by use of force, assault by means of force likely to produce great bodily injury, and false imprisonment. The information also alleged a multiple victim enhancement for counts 1 through 7 under Penal Code section 667.61, subdivisions (b) and (e).
Holman's competency to stand trial was questioned multiple times during the proceedings. In June 2022 and December 2023, defense counsel declared doubts about Holman's mental competence, leading to referrals to the mental health court. Dr. Shakib-Beltran and Dr. D'Ingillo examined Holman and concluded he was competent, finding he was exaggerating or feigning symptoms to avoid trial. Dr. Wagreich prepared a short report stating it was 'quite apparent' Holman was feigning his mental and cognitive disorders, but recommended a long report given the serious charges. The mental health court declared Holman competent in February 2024 based on Dr. Shakib-Beltran's report and again in August 2024 based on Dr. D'Ingillo's findings.
At trial in October 2024, Holman caused multiple disruptions, including outbursts, altercations with deputies, and refusing to attend proceedings. Despite these disruptions, he testified in his own defense, claiming the sexual encounters were consensual. The People dismissed counts 6 and 7 before closing arguments because they were unable to locate Maranda A. and have her testify at trial. The jury found Holman guilty on the remaining counts and found the multiple victim allegations true as to counts 1, 2, 4, and 5. The trial court sentenced him to an aggregate term of 60 years to life plus 10 years eight months.
The Court’s Holding
The Court of Appeal rejected Holman's argument that the trial court should have initiated a third competency hearing. The court explained that when a defendant has already been found competent, a new hearing is required only if there is a substantial change of circumstances or new evidence casting serious doubt on the prior finding. The court found substantial evidence supported the trial court's determination that Holman's trial disruptions were voluntary decisions to lash out when he did not get what he wanted, consistent with the prior psychiatric findings that he was malingering.
The court distinguished People v. Murdoch and People v. Rodas, where defendants had severe mental illnesses that rendered them incompetent without medication. In contrast, three psychiatrists found Holman's symptoms were volitional and feigned, and two of them concluded he was competent. The record showed Holman could behave properly when he chose to, as demonstrated by his ability to testify at length without incident when it was his turn.
Regarding CALCRIM No. 361, the court assumed without deciding that giving the instruction was error but found it harmless under the Watson standard. The instruction's conditional language, other properly given instructions on the burden of proof and witness credibility, and the prosecutor's closing argument that emphasized the People's burden all mitigated any potential prejudice. The court also rejected Holman's cumulative error claim because neither alleged error caused prejudice.
Key Takeaways
- A trial court need not hold a new competency hearing when a defendant has already been found competent unless presented with a substantial change of circumstances or new evidence casting serious doubt on the prior finding.
- Bizarre or disruptive behavior alone is insufficient to raise a doubt about competency; the court may rely on prior psychiatric findings that the defendant is malingering.
- A defendant's ability to testify coherently and comply with court procedures when he chooses to do so supports a finding of competency despite disruptive behavior at other times.
- Even if giving CALCRIM No. 361 is error, it may be harmless if the instruction's language emphasizes the prosecution's burden, other instructions properly inform the jury, and the prosecutor does not rely on the defendant's failure to explain or deny evidence in closing argument.
- Cumulative error claims fail when the individual alleged errors did not cause prejudice.
Why It Matters
This decision reinforces the deference appellate courts give to trial courts' competency determinations, particularly when multiple psychiatric evaluations have found the defendant competent and malingering. It clarifies that defendants who engage in disruptive behavior but demonstrate the ability to understand proceedings and assist counsel when they choose to do so are not entitled to repeated competency hearings.
The ruling also provides guidance on harmless error analysis for CALCRIM No. 361, emphasizing that the instruction's conditional language and the overall context of the trial, including other instructions and closing arguments, are relevant to determining whether any error was prejudicial.